United States securities and exchange commission logo
February 27, 2024
John Srivisal
Chief Financial Officer
Tronox Holdings plc
263 Tresser Boulevard , Suite 1100
Stamford, Connecticut 06901
Re: Tronox Holdings plc
Form 10-K filed
February 22, 2023
Response dated
February 2, 2024
File No. 001-35573
Dear John Srivisal:
We have reviewed your February 2, 2024 response to our comment
letter and have the
following comment.
Please respond to this letter within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe a
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your response to this letter, we may have
additional comments. Unless
we note otherwise, any references to prior comments are to comments in
our December 22, 2023
letter.
Form 10-K for the Fiscal Year Ended December 31, 2022
Item 15. Exhibits, Financial Statement Schedules.
Exhibits 96.1, 96.2, 96.3, and 96.4, page 106
1. We note your response
to comment 24, and that your proposed draft disclosure includes
average annual cash
flows. Please confirm that your revised technical report summaries
will include cash flows
on an annual basis, rather than average annual basis, to comply
with Item
601(b)(96)(iii)(B)(19)(iii) of Regulation S-K.
Please contact John Coleman at 202-551-3610 or Craig Arakawa at
202-551-3650 with
any questions regarding the comment. Please contact Jeanne Baker at
202-551-3691 or Terence
O'Brien at 202-551-3355 if you have any other questions.
John Srivisal
Tronox Holdings plc
February 27, 2024
Page 2
Sincerely,
FirstName LastNameJohn Srivisal
Division of Corporation Finance
Comapany NameTronox Holdings plc
Office of Industrial Applications and
February 27, 2024 Page 2 Services
FirstName LastName